Bringing a hazardous substance into your facility triggers a host of training requirements. Identifying and complying with these requirements can be even trickier when the chemical is covered by training rules from multiple government agencies. For companies handling hazardous substances, training obligations that often overlap come from:

• Department of Transportation (DOT);
• Occupational Safety and Health Administration (OSHA); and
• Environmental Protection Agency (EPA).

Let’s follow the training path created by bringing the hazardous substance formaldehyde to a hypothetical company — HypoCo, Inc. By identifying various training obligations, “Edna,” the EHS manager at HypoCo, saves time by covering all required elements in one training session for affected employees.

Transporting chemicals onsite

Hazardous materials that are released from their packaging pose a risk to the safety of people and the environment. Whenever hazardous materials are transported, the possibility exists for an unintentional release, no matter how much care is taken in their handling. Because of this, DOT training obligations begin at HypoCo before the drums of formaldehyde solution arrive at the loading dock.

To ensure safety during transportation, Edna trains, tests, and certifies every hazardous materials (hazmat) employee who has any function directly affecting the safe transport of the formaldehyde. This includes any employee who:

• loads, unloads, or handles the formaldehyde;
• prepares the formaldehyde for transportation;
• is responsible for safely transporting the formaldehyde; or
• operates a vehicle used to transport the formaldehyde.

Edna makes sure that all drivers and loading dock workers at HypoCo receive general awareness/familiarization, function-specific, safety, security, and modal-specific training. Even the shipping/receiving clerks receive training, so they understand the paperwork they process for the shipments of formaldehyde.

Safe use of chemicals

Exposure to formaldehyde can cause serious, irreversible health effects. This can happen through inhalation, by contact with skin, and if the substance is swallowed. Because of the danger, OSHA rules address safe use of the chemical in the workplace.

Depending on the exposure activities of employees in the facility, various training requirements apply. For instance, specific training is necessary for employees who:

• store or handle the formaldehyde;
• use the formaldehyde in a process; and
• respond in the event of a spill or leak.

Since employees could be harmed by exposure to formaldehyde, those who may work around the chemical at HypoCo are trained to understand its dangers and how to use it safely. Training is provided even for employees who only handle sealed containers, like in warehouse operations. Edna uses the elements from OSHA’s hazard communication (hazcom) standard for this training.

Because HypoCo stores and uses formaldehyde in large amounts, OSHA’s process safety management (PSM) rules apply. Hazcom training informs employees about the chemicals they work with and helps them understand material safety data sheets. But since the formaldehyde is used in a process at HypoCo, Edna provides additional training in operating procedures, safe work practices, safety procedures, and other areas specific to using the formaldehyde safely in a process.

In case the formaldehyde spills in the facility, Edna trains employees who participate in emergency response. This training falls under OSHA’s hazardous waste operations and emergency response (HAZWOPER) rule, and is based on each employee’s level of responsibility. Edna notes that these levels in emergency response can be as simple as pulling an alarm before evacuating, or as complex as controlling and cleaning up a major spill. She trains employees according to their specific assignment in a response.

Some workers who handle the formaldehyde must use personal protective equipment (PPE). Edna wants to make sure that they understand the purpose for, the proper use of, and the limitations of the equipment and clothing. These employees receive training before they are allowed to do work requiring PPE. As part of this training, all employees who use respirators (including potential use, as with emergency escape respirators) are trained in their proper use and limitations prior to expected use.

Because of the wide number of chemicals used in the laboratory, and the very small quantities, employees who use formaldehyde in the lab at HypoCo receive special training adapted to their use of the chemical.

Some chemicals have unique hazards and are specifically addressed in OSHA regulations (see sidebar). Edna knows that formaldehyde is one of these chemicals, and provides employees with the required specialized information and training.

EPA & worker safety

Generally, EPA is concerned with protection of the environment — not worker safety at a facility. But there is some crossover when it comes to certain hazardous substances and employee training.

Since using formaldehyde at HypoCo creates the potential for dangerous offsite consequences from chemical accidents, EPA’s risk management program rules apply. Under this program, Edna makes sure that each employee operating the formaldehyde process understands and adheres to the current operating procedures.

Edna also knows that workers using pesticides must be trained under EPA rules. Because the formaldehyde is not being used as a pesticide at HypoCo, Edna does not include those training elements in her program.

Disposal issues

Because of the characteristics of the formaldehyde solution, it becomes a hazardous waste after it is used in the process at HypoCo. Edna knows that even unused formaldehyde sent for disposal (like a drum with a few gallons left in the bottom) is hazardous waste. Spill cleanup materials and some of the empty containers may also qualify as hazardous waste. Here again, Edna knows that there are training rules that apply from more than one agency.

OSHA: Due to the seriousness of safety and health hazards related to hazardous waste operations, employees and managers who work at the hazardous waste storage facility at HypoCo receive training under OSHA’s HAZWOPER rule. Edna provides special training to these employees to protect them in this environment and help them handle hazardous waste safely and effectively.

EPA: Because of the volume of waste formaldehyde generated at HypoCo, the company is a hazardous waste generator under EPA rules. If employees have waste-handling duties, Edna trains them in emergency response procedures relevant to their responsibilities.

Some hazardous wastes generated at HypoCo are sent for recycling and are classified as universal waste. Wastes in this category include batteries, fluorescent and other lamps, pesticides, and mercury-containing equipment. Because of the special handling requirements, Edna trains all employees who handle or manage the company’s universal waste.

DOT: When they send formaldehyde waste offsite for disposal, HypoCo uses a hazardous waste manifest as the shipping document. Under DOT rules, Edna trains the individual who signs the shipper’s certification on shipping papers (including manifests) in all phases of hazmat transportation. Since the employee certifies that the materials are properly classified, described, packaged, marked, and labeled and in proper condition for shipment, Edna makes sure the employee receives:

function-specific training so they are knowledgeable in those areas and can determine that a formaldehyde waste shipment is in compliance with DOT rules, and

general awareness/familiarization and safety training.

It’s worth your time

As you can see, bringing just one hazardous chemical into your company can dictate the need for various levels of training affecting multiple employees. Once you’ve identified your training obligations, you can save time and money by developing content for training sessions that satisfies the requirements of multiple agencies.

While it definitely takes time and effort, a well-executed training program can result in improved compliance, lower operating costs, and a safer work environment.

SIDEBAR: Chemicals with specific OSHA training requirements include:

• formaldehyde
• liquefied petroleum gases
• anhydrous ammonia
• certain carcinogens
• vinyl chloride
• inorganic arsenic
• lead
• cadmium
• benzene
• 1,2-dibromo-3-chloropropane
• acrylonitrile
• ethylene oxide
• 4,4’-methylenedianiline
• 1,3-butadiene
• methylene chloride